Douglas v Commissioner of Inland Revenue - [2006] 1 NZLR 513

Practice and procedure — Defences — Issue estoppel and res judicata — Tax avoidance scheme subject of much litigation — Whether appellants estopped from raising issues argued in previous litigation as res judicata — Whether issue estoppel — Whether sufficient mutuality of interest between parties.

Revenue — Income tax — Company restructuring scheme known as “Russell template” — Tax avoidance scheme subject of much litigation — Whether appellants estopped from raising issues argued in previous litigation as res judicata — Whether issue estoppel — Whether sufficient mutuality of interest between parties — Whether individual assessments unintelligible — Income Tax Act 1976, ss 23, 25(2), 35, 99 and 191.

Revenue — Administration — Assessments — Whether individual assessments unintelligible — Standard for judging intelligibility.